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Reopening of assessment u/s 147 - Perusal of the reasons extracted elsewhere in this order only referred...

Reopening of assessment u/s 147 - Perusal of the reasons extracted elsewhere in this order only referred to the issue of classification of royalty on merits and nowhere it is stated that there has been any failure by the petitioner in making a disclosure in this regard. To be fair to the Assessing Officer, he does not even make such allegation in the reasons for re-assessment and rightly so, since the material available would show a full disclosure by the petitioner at all stages of assessment - Reassessment order quashed - HC .....

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